IR 05000324/1993046

Insp Repts 50-324/93-46 & 50-325/93-46 on 931004-08.No Violations Noted.Major Areas Inspected:Licensee Rc Program, Review of HP Activities,Organization & Staffing,Training & Qualifications & Internal & External Exposure Controls

ML20059K917
Person / Time
Site:	Brunswick
Issue date:	11/04/1993
From:	Rankin W, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059K895	List: IR 05000324/1993046 ML20059K893
References
50-324-93-46, 50-325-93-46, NUDOCS 9311160238
Download: ML20059K917 (13)

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UMITED STATES

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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA STREET. N.W.. SUITE 2900

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^E ATLANTA, GEORGIA 30323 0199

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Report Nos.:

50-325/93-46 and 50-324/93-46

Licensee: Carolina Power and Light Company P. O. Box 1551

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Raleigh, NC 27602

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Docket Nrs.:

50-325 and 50-324 License Nos.: DPR-71 and DPR-62

i Facility Name:

Brunswick I and 2 Inspection Conducted: October 4-8, 1993 j

Inspector:

Mdvt 8 b /', E

/05/ 6

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E. D. Testa, P. E:

Date Signed s

Approved by:

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t W. H. Rankin, P.E., Chief Dfte/ Signed Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch-i Division of Radiation Safety and Safeguards

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SUMMARY

.i Scope:

This routine, announce<1 inspection of the licensee's radiation control (RC)

program involved a review of health physics (HP) activities...cluding i

organization and staffing; training and qualifications; internal and external

exposure controls; and control of radioactive material. The inspection involved an indepth review of ALARA program implementation and initiatives since the special team inspection of October 12-16, 1991 (Inspection Report'

Nos. 50-325/91-23 and 50-324/91-23). Licensee corrective actions-on previously identified Violations (VIDs) and Inspector Follow-up Items (IFIs) were

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reviewed for closure.

Results:

Based on observations, interviews with licensee management, supervision,'

personnel from station departments, and records review, the inspector-found the licensee's program for occupational radiation safety was functioning

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adequately to protect the health and safety of the radiation workers. - The

licensee's efforts to effectively implement new 10 CFR Part 20 limits were viewed as a program strength. Improvements were noted in overall posting and i

control of radiation areas. The ALARA program was successfully working to reduce personnel exposure and reduce out of core radiation source terms.

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9311160238 93I104

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REPORT DETAILS i

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Persons Contacted

i Licensee Employees

• G. Barnes, Manager, Unit 1 Operations

• M. Bradley, Manager, Nuclear Assessment Department

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• J. Cowan, Plant Manager, Unit 1 l'

• J. Crider, Manager, Inservice Inspection

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• J. Dobbs, Special Assistant, Brunswick Steam Electric Plant

• J. Ferguson, Manager, Material and Cost Control

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• L. Gard, Manager, Engineering Projects

• R. Godley, Manager, Regulatory Programs

• C. Hinnant, Director, Site Operations t

• P. Leslie, Supervisor, Security

• W. Levis, Manager, Regulatory Affairs

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• R. Lopriore, Manager, Unit 1 Maintenance l

• J. Lyash, Manager, Operations Support

• J. McGowan, Special Investigator, Regulatory Compliance

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• A. Padleckas, First Line Supervisor, Inservice Inspection

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• C. Robertson, Manager, Environmental and Radiation Control i

• R. Schlechner, Lead Assessor, Nuclear Assessment Department

• S. Tabor, Senior Special Investigator, Regulatory Compliance

• G. Thearling, Senior Special Investigator, Regulatory Compliance t

• J. Titrington, Manager, Unit 2 Operations

• E. Willett, Manager, Project Management Other licensee employees contacted included engineers, technicians, and office personnel.

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Nuclear Regulatory Commission

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• P. Byron, Resident Inspector

• H. Christensen, Chief, Project Section lA e

• G.

Harris, Inspector, Project Section lA

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• M. Janus, Resident Inspector

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• R. Prevatte, Senior Resident Inspector

• W. Stansberry, Security Inspector i

• H. Whitener, Inspector, Test Programs Section

• Attended October 8, 1993 Exit Meeting 2.

Organization and Staffing (83729)

I The inspector reviewed and discussed with licensee representatives

changes made to the Radiation Control'(RC) organization since the last

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inspection of'this area conducted April 12-16, 1993, and documented in

Inspection Report (IR) 50-325/93-18 and 50-324/93-18. As a result of realignment of corporate support, the site has added several new-

positions. Two Senior Specialists have been added, one specialist to

coordinate training for the Environmental and Radiation Control (E&RC)

Staff and the other to provide professional support for the health i

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physics (HP) program. These positions have been filled by former corporate support personnel. Seven additional RC technicians have been

added and at the time of this inspection, the selection process for i

these positions was underway. One additional RC Supervisor.has been

.i added to supervise the seven additional technicians. At the time of the

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inspection the selection process for this position was in progress. The

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E&RC Unit has been approved to increase permanent staffing from 108 to 120 personnel.

The licensee continued to maintain an experienced core technician staff

of junior and senior technicians. The technician staff included senior

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technicians, junior technicians, and HP clerks.

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Based on discussions with licensee representatives and observations of

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activities in progress, no concerns were identified regarding the

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licensee's organization and staffing. The staffing level appeared

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adequate to support the activities associated with the operation of one l

unit and the ongoing and planned activities of the other unit.

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No violations or deviations were identified in this area.

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3.

Audits and Appraisals (83729)

The inspector reviewcJ the licensee's self assessment program for identification and correction of radiological deficiencies. The

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inspector interviewed Nuclear Assessment Department (NAD) personnel who perform the NAD audits and also reviewed the latest NAD Audit which was

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performed for the Brunswick Startup Readiness Assessment (Report number

!93-508), dated September 8, 1993. The inspector found the NAD audit i

detailed and probing. The audit pointed out a continuing problem in the

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area of management of contractors involved in refuel floor activities.

l The audit discussed several events which resulted in three Adverse

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Condition Reports (ACRs). These ACRs fully captured 'the problems and immediate corrective actions were identified and close out of the issues

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are currently in the resolution stages of their corrective program.

Radiological Event Reports (RERs) were filed and consisted of radiological deficiencies or minor violations of HP procedures. These RERs were documented for the purposes of tracking, trending, ad performing corrective action to minimize recurrence of deficiencies and improve the quality of the radiological control program.

Selected RERs were reviewed by the inspector and determined to be substantive with adequate corrective actions assigned.

In general, the inspector found the licensee's NAD Audit and Appraisal program to be adequate for self-identification of radiological findings.

In addition, corrective actions to findings were accomplished in a timely manner.

No violations or deviations were identified in this area.

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Planning and Preparation (83729)

The inspector discussed with licensee representatives the planning and preparation for the current extended outage for Unit I which included HP

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staffing, training, equipment, dose reduction methods to be employed,

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decontamination efforts, radwaste reduction and work scope sequencing.

Unit 1 outage work was coming to an end in anticipation of restart and much of the HP work was supporting closecut and cleanup.

r The licensee has a plan to transport 24 railcars of spent fuel prior to i

the end of the calendar year. The inspector independently reviewed the i

posting and performed radiation surveys on two railcars ready for r

shipment and found no problems.

No violations or deviations were identified in this area.

5.

Radiation Protection Training (83729)

10 CFR 19.12 requires, in part, that the licensee instruct all individuals working in or frequenting any portion of a restricted area in the health protection aspects associated with exposure to radioactive material or radiation; in precautions or procedures to minimize exposure; in the purpose and function of protection devices employed; in the applicable provisions of the Commission regulations; in the individual's responsibilities; and in the availability of radiation exposure data.

The inspector reviewed procedure 0-E&RC-0230 titled,. " Issue and Use of

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Radiation Work Permit", Revision 28, dated March 18, 1993. The procedure is used to control personnel exposures through the use of a radiation work permit (RWP) which authorizes specific tasks and entries into areas of known or possible radiation hazards. Special RWPs are required for specific plant locations and tasks and are valid for the duration of the job (up to one year). General RWPs are used by individuals requiring an RWP whose work does not require stringent radiation controls..seneral RWPs are not valid for entry into restricted or very high radiation areas, initial drywell entries, and entries when the reactor is critical. The procedure also requires that each individual be responsible for signing the RWP Signature Log before going to work on an RWP. This signature is only required the first time an individual signs on the RWP and with each subsequent revision of the RWP to be worked by that individual. Signing of the RWP SIGNATURE LOG signifies that the worker has read and understands the current revision of the RWP being logged in on. The inspector questioned a selected group of workers and found that they were knowledgeable about their RWP and had read the cautions and precautions. They were also aware that it was their responsibility to ensure that they were properly logged on the RWP prior to work start.

For the RWPs reviewed, the inspector noted that

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appropriate protective clothing, respiratory protection, and dosimetry were required. The inspector found the licensee's program for RWP implementation to adequately address radiological protection concerns, F

and to provide for proper control measures.

The inspector also observed briefings corducted for workers prior to entering the radiologically controlled are.1 (RCA).

The briefings included reviews of current radiation serveys with emphasis on high dose'

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areas and low dose waiting areas. Workers were also informed about the locations of hot spots in an overall work area and cautioned not to work

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six feet or in the overhead without notifying HP. All workers entering radiation areas were advised of their remaining available exposure. The interaction between HP and the workers entering the RCA, in this regard, was considered adequate.

The inspector also reviewed General Employee Training for Visitor Access j

i Level 1, Initial / Retraining Levels 1 & 2 Self-Study Guide (Revision 11, dated May 7,1993), and Self-Study Guide Plant Specific Training (LPN-17

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GRN51N). The training material provided an acceptable level of instruction for working in a radiation area.

Based on the review of selected training procedures course outlines and

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selected worker interviews the inspector determined that the licensee's GET program met the provisions of-10 CFR 19.12.

i No violations or deviations were identifiec in this area.

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External Exposure Controls (83729)

10 CFR 20.1201(a),(b),(c),(d),(e), and (f) requires that the licensee shall control the occupational dose to individual adults to annual limits specified.

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Personnel Dosimetry

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10 CFR 20.1502(a) requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipment.

10 CFR 20.1501(c) requires that dosimeters used to comply with 10 CFR 20.1502(a) shall be processed and evaluated by a processor accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for the types of radiation for which the individual is monitored.

The inspector selectively reviewed the licensee's dosimetry program to ensure the licensee was meeting the monitoring requirements of new 10 CFR Part 20. During tours of the plant, the inspector observed proper use of thermoluminescent dosimeters (TLDs) and self reading dosimeters (SRDs).

No violations or deviations were identified in this area.

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Whole Body Exposure The inspector discussed the cumulative whole body exposures for l

plant and contractor employees. Licensee representatives stated.

i and the inspector independently confirmed that all whole. body

exposures assigned since the previous NRC inspection of this area were within 10 CFR 20 limits. -The licensee had not granted any

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administrative dose extensions as of October 8, 1993.

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No violations or deviations were identified in this area.

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Notices to Workers

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10 CFR 19.11(a) and (b) require, in part, that the licensee post a

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current copies of 10 CFR 19, 20, the license, license conditions, documents incorporated into the license, license amendments and i

operating procedures, or that a licensee post a notice describing i

these documents and where they may be examined.

10 CFR 19.ll(d) requires that a licensee post NRC Form-3, Notice to Employees.

Sufficient copies of the required forms are to be

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posted to permit licensee workers to observe them on their way to or from licensee activity locations.

t During the inspection, the inspector verified that NRC Form-3 was

posted properly at various plant locations permitting adequate j

worker access.

In addition, notices were posted referencing the

location where the license, procedures, and supporting documents

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could be reviewed.

No violations or deviations were identified in. this area.

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Control of Radiative Material and Contamination, Surveys, and Monitoring l

(83729)

j 10 CFR 20.1501(a) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate i

the extent of radiological hazards that may. be present.

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Posting and Labeling 10 CFR 20.1904(a) requires, in part, each container of licensed material containing greater than Appendu C quantit'.es to her a durable, clearly visible label identifying the raJioactive contents and providing sufficient information tc permit individuals handling or using the containere., or working in the vicinity thereof, to take precautions to a vid or minimize exposures.

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During tours of the Unit I and Unit 2 Reactor Building,. Unit 1 Turbine' Building, Radioactive Waste Processing Building and various radioactive material storage locations, the inspector independently verified that selected radioactive material areas were appropriately posted and that selected containers were

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labeled consistent with regulatory requirements.

No violations or deviations were identified in this area.-

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Personnel and Area Contamination

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The licensee maintained approximately 50,338 square feet (ft ) of floor space as contaminated as of August 1,1993. This represented approximately nine percent of the RCA.

As of September, 1993, approximately 262 Personnel Contamination Events (PCEs) had occurred. The PCEs consisted of approximately 189 clothing contaminations and approximately 73 skin contaminations. For 1993, PCEs have averaged 0.77/1000 RWP entries.

PCEs have been on a steady decline at the Brunswick Nuclear Plant. The inspector reviewed the Personnel Contamination Investigation Log and randomly selected several investigations for review. The investigations were found to be detailed and corrective actions where necessary were implemented. Licensee improved contamination control practices and have reduced PCEs from 652 in 1989 to 262 in 1993. Considering the long outages and scope of work this is an indication of good personnel contamination control.

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There were a total of 144 " Clean area" contaminations. There was a significant amount of resurfacing of floors and the number of foot

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contamination (122 PCEs) appeared to be associated with low levels

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of activity from flecks of slightly contaminated old floor surfaces which were loosened during floor surface, preparation.

Unit 1, in addition, has had a major paint and coating campaign.

Surface preparation for the dados, pumps, pipes and subsequent painting provided a tough challenge to keep the number of PCEs controlled. The plant looks extremely clean and the new surfaces increased the brightness in the areas for worker safety and the coatings provide a surface more easily decontaminated. The highest number of personnel contaminations have been attributed to contract personnel.

During plant tours, the inspector observed adequate housekeeping and contamination control practices. The inspector observed handling, packaging, and surveying of contaminated equipment for movement and judged the work evaluations satisfactory.

No violations or deviations were identified in this are ~.

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High Radiation Areas

TS 6.12.1 required, in part,'that each High Radiation Area (HRA)

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with radiation levels greater than or equal to 100 mrem /hr but

less than or-equal to 1000 mrem /hr be barricaded and conspicuously i

posted as a HRA.

In addition, any individual'or group of

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individuals permitted to enter such areas are to be provided with.

or accompanied by a radiation monitoring device which continuously i

indicates the radiation dose rate in the area or a radiation

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monitoring device which continuously integrates the dose rate in i

procedures with a radiation dose rate monitoring device.

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the area, or an individual qualified in radiation protection

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During tours of the Unit I and Unit 2 Reactor Building, Turbine

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Building, and Radioactive Waste Processing Building, the inspector

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noted that all HRAs and locked HRAs were locked and/or posted, as

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required.

Independent surveys performed by the inspector

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concluded the licensee had been successful in their efforts to

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reduce general area radiation levels in various areas by

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hydrolazing numerous clogged floor drains. The inspector reviewed the Reactor Building and Turbine Building Floor Drain Decon Status

as of October 8, 1993 and found the following:

F Exposure Reducina Activity

'Results Flex lance Unit 1 and Unit 2 Expended 3 person-rem to yield

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Reactor Building floor drains an annual exposure savings

estimated to be in excess of.

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30 person-rem.

Eight (8) posted hot spots had their sources removed and were

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then deposted.

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Exposure savings from

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i decontaminating the RWCU floor

drains estimated to be in excess of 13 person-rem.

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Operator work arounds due to poorly f'owing floor drains were eliminated in both units.

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Drain status:

i 30 drains complete in U-2 TB-82 drains complete in U-2 RB'

i 12 oily drains complete in U-2 TB-

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l 56 drains complete in U-1 TB l

54 drains complete in U-1 RB

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12 oily drains complete in

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43 drains remain to'be cleared

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in the U-1 RB

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i Project will be complete in U-1 11/29/93 Flex lance Unit 2 scram Decontamination factor of 8 on discharge header the north header and 3 on the south header.

Reduced general area (GA)[ dose rr.tes from 8-12 mrem /hr down to 2 mrem /hr.

Removed temporary shielding-

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from the header.

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Deposted area as a High Dose I

Area.

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Flex lance Unit I scram Deposted area as a High Dose

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discharge header Area.

Dose rates'on header: reduced i

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from as high as 300 mrem /hr-down to less than 50 mrem /hr.

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Flex lance Unit 1 Southwest Reduced GA~ dose rates (next pipe chase to RBI airlock) from

10-15 mrem /hr.

Removed the temporary shield '

rack previously installed.

Developed and Implemented Utilized successfully on three

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Remote Valve Decontamination (3) large bore valves.

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Device Exposure savings (from decon alone) estimated to be

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1.2 person-rem.

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Critical Path Time savings of'about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. (Cut'decon time by at least 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.)'

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Reduced work area dose rates

from 250-300 mrem /hr down to 100 mrem /hr.

Hydrolazing of the Outer Bellows Allowed vessel' disassembly'

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respiratory protection.

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l disassembly by 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

• Saved approximately 2 person-rem.

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The inspector determined that there were significant person-rem savings and GA dose rate reductions due to the hydrolazing efforts.

No violations or deviations were identified in this area.

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Radiation Detection and Survey Instrumentation e

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During facility tours, the inspector noted that survey

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instrumentation and continuous air monitors in use within the RCA were operable and displayed current calibration stickers..The inspector further noted an adequate number of survey instruments

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were available for use, and background radiation levels at personnel survey locations were observed to.be within the

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licensee's procedural limit of 300 counts per minute (cpm).

No violations or deviations were identified in this area.

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Independent Surveys During facility tours, the inspector independently verified

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radiation and/or contamination levels in Unit 1 and Unit 2 Reactor Building, Turbine Building, Radioactive Waste Processing Building areas, and other radioactive material storage areas including the..

Low Level Waste Handling Building. 'The inspector also performed radiation surveys of selected HRA boundaries including posted Hot Spots. The inspector reviewed the Hot Spot Engineering Data Report, the hot spots being tracked and the priorities. assigned to i

work on the hot spots for dose reduction. There are a total of 59 hot spots being tracked in Unit 1 and 26 in Unit 2. The

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licensee has contact and 30 cm. survey readings for each of the identified spots and an action plan to reduce the dose associated with the spots. This plan includes but is not limited to the following:

flush, cut out, shield or make the area inaccessible workers are made aware of hot spots during RWP briefings.

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No violations or deviations were identified in this area.

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Program for Maintaining Exposures As low As Reasonably Achievable (83729)

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10 CFR 20.1101(b) states that the licensee shall use, to the extent

practicable, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses to members

l of the public that are as low as reasonably achievable (ALARA).

Regulatory Guides 8.8 and 8.10 provide information relevant to attaining

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goals and objectives for planning and operating light water reactors and

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provide general philosophy acceptable to the NRC as a necessary basis t

for a program of maintaining occupational exposures ALARA.

j During the inspection, the inspector reviewed and discussed with

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cognizant licensee representatives ALARA program initiatives and i

implementation for 1993 year-to-date. The inspector reviewed and discussed the status of the ALARA Suggestions Program implemented by the

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licensee and determined the program to be an effective measure used by the licensee to reduce exposure. As of the date of the inspection,.

111 ALARA suggestions have been received for the calendar year 1993. The licensee tracks the suggestions. A total of 28 suggestions had been

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evaluated and implemented. Thirty-five suggestions were evaluated and i

not implemented. An estimated 26.5 person-rem were saved thru

implementation of the 28 suggestions. Through~ August a total of l

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557 suggestions had been received in the program since its inception.

Historically, about 47 percent (262) had been implemented, 35 percent l

(196) evaluated and not implemented and 18_ percent (99) were awaiting

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resolution. Outage doses have continued to trend downward and GA l

radiation levels have been reduced as a result of improved ALARA pre-planning packages, briefings, and area and system decontamination effectiveness. The licensee has data which indicates that Brunswick ranks 13 out of 26 BWRs in collective radiation exposure in 1992. The 1992 average was calculated to be 367 person-rem per unit with a range of 81 to 710 person-rem. Brunswick's per unit dose for 1992 was 312.

Because of the extended forced outage of both units the 1993 goal for the plant was set as 850 person-rem or 425 person-rem per unit. At the time of the inspection, a total of approximately 760 person-rem had been received by the workers. The yearly goal appeared to be achievable based on the activities planned and scheduled for the remainder of the year.

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The inspector reviewed the comparison of the site respirator usage with

the implementation of the new 10 CFR Part 20.

Total Respirators Used Third and Forth Quarter 1992 7279 Old 10~CFR 20,

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First and Second Quarter 1993 4657 New 10 CFR 20

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i This is reduction of about 36 percent, This reduction was accomplished

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with little or no facial PCE increase and minimal internal uptakes. All

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uptakes were small percentages of regulatory limits.

The inspector selectively reviewed the following ALARA initiatives:

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Mockup use

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Chemical Decontaminations of Systems

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Temporary Shielding

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Valve Cobalt Elimination Program

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In-Vessel Cobalt Elimination (Control Blade roller replacement)

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The inspector determined that the licensee was aggressively implementing l

these ALARA initiatives and was achieving a significant reduction of personnel doses.

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The inspector reviewed the Reactor Water Clean Up (RWCU) phase separator

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room cleanup implementation schedule. At the time of the inspection the project was scheduled to be' completed by the end of the calendar year.

This project would reclaim the area in the -3ft RWCU phase separator

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tank room, reduce potential contamination problems, and reduce GA dose.

O This job has been planned to use robots to remove the previously spilled

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resins for disposal.

No violations or deviations were identified in this area.

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Licensee Actions on Previously Identified Inspector Followup Items (IFIs) (92702)

a.

(Closed) 50-325,324/93-18-01:

Clearly define ownership for.the Spent Fuel Shipping Project.

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The inspector reviewed the project organization and the results of the multiple shipments already completed and determined that the organization was effectively managing the shipments.

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(Closed) 50-325,324/92-32-02:

Review Unit 2 Ventilation System actions associated with recovery from the September 22, 1992 Am-241 event.

The inspector reviewed the licensee's calculations for the amount.

of Am-241 contamination available in the Unit 2 ventilation system available for resuspension and transport out of the duct work and -

fan room. The licensee determined that the impact from the resuspension although a nuisance contamination problem that had to

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- i be monitored was an ALARA TEDE minimal health risk.- The licensee

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was preparing tags to be posted on duct access doors to warn of

the Am-241 contamination.

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12.

Licensee Actions Regarding Previous Enforcement Items-

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(Closed) VIO 50-325,324/93-28-01: An Auxiliary Operator issued i

an alarming dosimeter when only HP is authorized to do so.

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The inspector reviewed the actions taken by the licensee as stated in their response to the violation. This was submitted in a letter dated July 30, 1993 Serial:

BSEP-93-0122. The inspector reviewed the corrective steps taken and the results achieved and determined that the problem had been corrected.

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(Closed) VIO 50-325, 324/93-28-02: The licensee failed to provide'

adequate information to operations personnel in the use of digital alarming dosimeters (DADS).

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The inspector reviewed the actions taken by the licensee as stated i

in their response to the violation. This was submitted in a letter

dated July 30, 1993 Serial:

BSEP-93-0122. The inspector reviewed the corrective steps taken and the results achieved and determined that the violation had been corrected.

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13.

Exit Meeting (83729)

The inspector met with licensee representatives indicated sin Paragraph I at the conclusion of the inspection on October 8,1993. The inspector summarized the scope and findings of the inspection. The ' inspector also discussed the likely information content of the inspection report with regard to-documents or processes reviewed by the inspector during the

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inspection. The licensee did not identify any such documents or

processes as proprietary. Dissenting comments were not received from

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the licensee.

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